Missouri Court of Appeals, Western District / Dec 22, 2020
Rylan Brantl vs. The Curators of the University of Missouri
Dr. Rylan Brantl sued The Curators of the University of Missouri for breach of contract and related state-law claims following the termination of his neurosurgery residency. The trial court dismissed Dr. Brantl's first amended petition with prejudice, finding his claims were barred by Missouri's five-year statute of limitations. The appellate court affirmed, holding that the claims accrued when Dr. Brantl received notice of his termination, not the formal termination date. The court further determined that federal supplemental jurisdiction tolling provisions did not apply to claims dismissed on Eleventh Amendment immunity grounds, and Missouri's savings statute could not revive time-barred actions.